Wednesday, November 27, 2013

2014 Outpatient Payment Rule Released by CMS

The Centers for Medicare and Medicaid Services (CMS) has issued a new rule for the Outpatient Prospective Payment System (OPPS) that will create 29 comprehensive Ambulatory Payment Classifications (APCs) to handle payment for the most costly device-dependent services, require direct supervision for a range of outpatient services in critical access hospitals (CAHs), and increase the payment rates under the OPPS by 1.7 %. The new rule will be effective January 1, 2014; however, CMS will delay implementation and final configuration of the new 29 comprehensive APCs until 2015.

The comprehensive APCs would treat all individually reported codes as components of a comprehensive service, resulting in a single prospective payment based on the cost of all individually reported codes. CMS will make a single payment for the comprehensive service based on all charges on the claim, and charges for services that cannot be covered separately by Medicare Part B or that are not payable under the OPPS will not be reimbursed. Although physical therapy services are typically paid separately under Medicare Part B, some therapy services would be considered part of the comprehensive service based on several factors. In general, physical therapy services that occur in the perioperative period would be paid under the comprehensive APC payment.

The new rule also establishes a direct supervision requirement for outpatient therapeutic services in CAHs, a change that CMS believes will ensure quality and safety. Additionally, the rule reiterates the requirement in the physician fee schedule that the therapy cap must be applied to CAHs.

APTA submitted comments regarding the proposed rule and will continue to monitor the effect that these provisions will have on physical therapy. APTA will post a detailed summary of the final rule shortly.

"The new rule also establishes a direct supervision requirement for outpatient therapeutic services in CAHs, a change that CMS believes will ensure quality and safety."
Can someone clarify what "direct supervision" means?

Posted by Eva Evans
on 11/29/2013 7:30 AM

what would be the impact on services provided by hospital based outpatient centers and non hospital based outpatient PT clinics with new rule?

Posted by reyna colombo
on 11/29/2013 9:17 AM

please clarify the specifics of the peripoperative period

Posted by Susan Carlson -> =JQ_>
on 12/1/2013 12:43 PM

I too wish to have clarification on the direct supervision requirement for CAHs.

Posted by Kelley Lester
on 12/1/2013 1:27 PM

If Direct supervision is meant to be applied to outpatient physical therapy services, in an underserved rural area for physicians, direct supervision is not possible. Not only that, this would be an insult to the licensure and training of physical therapist's working in a CAH. This insinuates that because we are working in a rural area we do not provide quality and safety??

Posted by Mollie Beyers
on 12/2/2013 8:30 AM

It appears that this was designed for "outpatient procedures". What is CMS considering to be an outpatient procedure? Is manual therapy or therapeutic execise a procedure? What exactly does CMS consider "outpatient therapeutic services"? This appears to be very vague and at first glance not focused on PT/OT/ST. Please give me some clarification. Michael Zeimantz PT

Posted by Michael Zeimantz
on 12/2/2013 6:48 PM

Regarding the APC's: Who gets paid the Comprehensive fee for the Bundled services? In the perioperative example given will the surgeon get the global fee? If so this is a windfall for POPTS. Or will the ACO be paid?
Cathy Anastasio

Posted by Catherine Anastasio -> EHYc
on 12/3/2013 10:43 AM

Please clarify the CAH's rule for direct supervision. We have the same training as every other therapist in the business. Why are we singled out??

Posted by Anita Zeigler
on 12/3/2013 11:12 AM

The Outpatient Prospective Payment System final rule for 2014 specifies that physical therapy services provided in CAHs and paid under the OPPS are subject to the direct supervision requirements in 42 CFR § 410.27. “Direct supervision” means that the physician or nonphysician practitioner (NPP) must be immediately available to furnish assistance and direction throughout the performance of the procedure. The physician or NPP is not required to be present in the room when the procedure is performed. Most physical therapy services provided in the outpatient hospital department are not paid under the OPPS and are paid instead under the Medicare Physician Fee Schedule. Services paid under the Medicare Physician Fee Schedule are not subject to the direct supervision requirements, whether they are furnished in OPPS hospitals or in CAHs. A small subset of ‘‘sometimes therapy’’ physical therapy services are paid under the OPPS when they are not furnished as therapy, meaning not under a certified therapy plan of care. CMS provides an annual update of these “sometimes therapy” services subject to direct supervision requirements. The update can be found at
http://www.cms.gov/Medicare/Billing/TherapyServices/AnnualTherapyUpdate.html